Commercial motor vehicles, and more specifically semi-trailer trucks, are commonly used to transport goods and materials throughout the United States. A semi-trailer truck is a combination of a powered truck-tractor and at least one unpowered semi-trailer that is attached to the rear of the truck-tractor and carried by the truck-tractor. A particular type of semi-trailer truck configured for transporting dry bulk solid goods and/or liquid materials combines a tank trailer with a tank tractor, which is also commonly known as a tank truck.
The Federal Motor Carrier Safety Administration (FMCSA) establishes rules and regulations governing commercial motor vehicles, including semi-trailer trucks. One such FMCSA regulation, entitled “Employee Safety and Health Standards” is codified at Title 49, Part 399 of the Code of Federal Regulations. Part 399 of Title 49 prescribes step, handhold and deck requirements on commercial motor vehicles that are intended to enhance the safety of motor carrier employees. Subpart 399.207 of Title 49 specifically addresses truck and truck-tractor access requirements, including the design, size and construction of steps for providing access to the rear portion of the truck or truck-tractor above the frame rails and behind the cab.
Through the years, the amount of hydraulic, pneumatic, mechanical and/or electrical equipment that is located on the rear of a truck or truck-tractor has increased dramatically. This is especially true in the case of a tank truck, which typically must be provided with equipment for loading and unloading both dry bulk solid good and liquid materials from a tank trailer, in addition to the mechanical, electrical and/or pneumatic equipment necessary to couple and uncouple the tank trailer and tank truck. As a result, the amount of space available on the rear of the tank truck, and in particular, along the frame rail of the tank truck behind the driver's side of the cab, has all but disappeared.
The previously mentioned Subpart 399.207 of the FMCSA regulations requires that steps be provided for accessing the rear portion behind the cab of a truck or truck-tractor. The steps must be of a minimum depth and a minimum width for two foot access. Steps in compliance with 49 C.F.R. § 399.207 are currently affixed to the rear portion of a tank truck at a convenient location along the length of one of the frame rails, typically on the driver's side of the tank truck. However, as the amount and/or the size of tank truck equipment provided on the tank truck has increased, there is less and less space available along the length of the frame rail to attach steps of sufficient size to accommodate both feet of a person accessing an area behind the cab on the rear portion of the thank truck. As a result, it has been necessary to relocate certain of the tank truck equipment to a less convenient location on the rear of the tank truck. Complying with the requirements of Subpart 399.207 has led to non-uniform and less desirable configurations of tank truck equipment on the rear of the tank truck, resulting in confusion and dissatisfaction among operators.
Accordingly, there exists an unresolved need for tank truck equipment having steps for accessing the rear portion of a tank truck above the frame rails and behind the cab of the tank truck. More particularly, there exists a need for tank truck having steps in compliance with the FMCSA regulations codified at Part 399 of Title 49 of the Code of Federal Regulations. There exists a specific need for a hydraulic oil cooler having steps for accessing the rear portion of a tank truck wherein the steps meet the specific requirements of Subpart 399.207 of the FMCSA regulations.